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Jointly proposed USP for TUSD 12-11-12

Jointly proposed USP for TUSD 12-11-12

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Published by DA Morales
Attached, please find the jointly proposed Unitary Status Plan (USP) that was submitted to the Federal District Court on December 10th, 2012 by the parties involved in the Desegregation case; the Fisher Plaintiffs; the Mendoza Plaintiffs; the United States Department of Justice Plaintiff- Intervenor; and Tucson Unified School District- Defendant. Special Master Hawley has, of course, been an intricate part of the USP development process. The proposed Plan denotes areas of disagreement by indicating the objections by each party to the litigation.
Attached, please find the jointly proposed Unitary Status Plan (USP) that was submitted to the Federal District Court on December 10th, 2012 by the parties involved in the Desegregation case; the Fisher Plaintiffs; the Mendoza Plaintiffs; the United States Department of Justice Plaintiff- Intervenor; and Tucson Unified School District- Defendant. Special Master Hawley has, of course, been an intricate part of the USP development process. The proposed Plan denotes areas of disagreement by indicating the objections by each party to the litigation.

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Published by: DA Morales on Dec 12, 2012
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08/25/2013

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STIPULATION OF THE PARTIES REGARDINGTHE FILING OF THE JOINT PROPOSEDUNITARY STATUS PLAN NOTING AREAS OFPARTY
DISAGREEMENT
LOIS D. THOMPSON, Cal. Bar No. 093245 (Admitted Pro Hac Vice)lthompson@proskauer.comJENNIFER L. ROCHE, Cal. Bar No. 254538 (Admitted Pro Hac Vice) jroche@proskauer.comPROSKAUER ROSE LLP2049 Century Park East, 32nd Floor Los Angeles, California 90067-3206Telephone: (310) 557-2900Facsimile: (310) 557-2193 NANCY RAMIREZ, Cal. Bar. No. 152629 (Admitted Pro Hac Vice)nramirez@maldef.orgMEXICAN AMERICAN LEGAL DEFENSE ANDEDUCATIONAL FUND (MALDEF)634 S. Spring St.11th Floor Telephone: (213) 629-2512 ext. 121Facsimile: (213) 629-0266Attorneys for Mendoza Plaintiffs
UNITED STATES DISTRICT COURTDISTRICT OF ARIZONA
ROY and JOSIE FISHER, et al., )Plaintiffs, ))UNITED STATES OF AMERICA, )Plaintiff-Intervenor, )) No. 74-CV-90-TUC-DCBvs. ) (lead case))ANITA LOHR, et al., )Defendants, ))and ))SIDNEY L. SUTTON, et al., )Defendants-Intervenors. )
STIPULATION OF THE PARTIES
)
REGARDING THE FILING OF THE
 )
JOINT PROPOSED UNITARY STATUS
 MARIA MENDOZA, et al., )
PLAN NOTING AREAS OF PARTY
 
Plaintiffs, )
DISAGREEMENT
 )UNITED STATES OF AMERICA, )Plaintiff-Intervenor, ))vs. )) No. 74-CV-204-TUC-DCBTUCSON UNIFIED SCHOOL DISTRICT ) (consolidated case) NO. ONE, et al., )Defendants. ) ___________________________________ )
!ase 4:74-cv-00090-D!B Document 1411 Filed 12/10/12 Page 1 of 91
 
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STIPULATION OF THE PARTIES REGARDINGTHE FILING OF THE JOINT PROPOSEDUNITARY STATUS PLAN NOTING AREAS OFPARTY
DISAGREEMENT
 The Fisher Plaintiffs, the Mendoza Plaintiffs, the United States (collectively, the“Plaintiffs”), and the Tucson Unified School District No. 1 (“TUSD,” or the “District”)(collectively, “the Parties”), by and through counsel undersigned, hereby submit this Stipulation insupport of the Joint Proposed Unitary Status Plan Noting Areas of Disagreement (the “December 10 Plan”) attached hereto as
Exhibit A
.Pursuant to this Court’s Order dated October 31, 2012, the Parties filed a Stipulation andJoint Proposed Unitary Status Plan Noting Areas of Party Disagreement on November 9, 2012(the “November 9 Plan”). The November 9 Plan was negotiated and drafted by the Parties; theSpecial Master was consulted in the creation of the November 9 Plan and his initial proposalswere considered and, to the extent possible, incorporated into that Plan.Subsequent to the filing of the November 9 Plan, the Parties and the Special Master conducted three public forums and received and reviewed public comments. The December 10Plan filed herewith includes changes made based on public comments and on further negotiations between the Parties, and includes only those objections which have not been resolved. Anyadditional proposals from the Parties will be raised in separate filings on December 14, 2012, or thereafter by the Special Master. The Parties are submitting the December 10 Plan as a consentdecree subject to those remaining objections.Respectfully submitted, this 10th day of December 2012.
 /s/Nancy Ramirez, by permission
RUBIN SALTER, JR., ASBN 01710Counsel for Plaintiffs Roy andJosie Fisher, et al
 /s/Nancy Ramirez, by permission
THOMAS E. PEREZAssistant Attorney GeneralCivil Rights DivisionANURIMA BHARGAVA, Chief ZOE M. SAVITSKYEducational Opportunities Section
!ase 4:74-cv-00090-D!B Document 1411 Filed 12/10/12 Page 2 of 91
 
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STIPULATION OF THE PARTIES REGARDINGTHE FILING OF THE JOINT PROPOSEDUNITARY STATUS PLAN NOTING AREAS OFPARTY
DISAGREEMENT
 Civil Rights DivisionU.S. Department of Justice950 Pennsylvania Avenue, NWPatrick Henry Building, Suite 4300Washington, D.C. 20530Tel: (202) 305-3223Fax: (202) 514-8337
 /s/Nancy Ramirez, by permission
DeCONCINI McDONALDYETWIN & LACY, P.C.Richard M. YetwinHeather K. GainesSesaly O. StampsCounsel for Defendant Tucson Unified SchoolDistrict
 /s/Nancy Ramirez 
PROSKAUER ROSE LLPLOIS D. THOMPSONJENNIFER L. ROCHEMEXICAN AMERICAN LEGAL DEFENSE ANDEDUCATIONAL FUND NANCY RAMIREZ
!ase 4:74-cv-00090-D!B Document 1411 Filed 12/10/12 Page 3 of 91

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